SECTION 4. FINALITY OF

CONVENTION ADOPTIONS

.01 Adoption finalized in another Con- vention country . If a taxpayer is within the

scope of this revenue procedure, the Internal Revenue Service will not challenge the taxpayer’s treatment of an adoption that is finalized in another Convention country (sending country) as final in the taxable year that either:

(1) The sending country enters a final decree of adoption, or

(2) The Secretary of State issues a certificate under § 301(a) of the IAA (IHAC).

.02 Adoption finalized in the United States . If a taxpayer is within the scope of this revenue procedure, the Service will not challenge the taxpayer’s treatment of an adoption of a child who has entered the United States for the purpose of adoption subject to § 301(c) of the IAA (IHCC) as final in the taxable year that a state court enters a final decree of adoption.